What happens to my U.S. LLC when I expatriate? Do I have to close it?
I'm a covered expatriate planning to surrender my green card. I own a single-member LLC that generates about $150,000 per year in revenue from U.S. clients. After I expatriate, can I still keep the LLC? Does it change how the LLC is taxed? I've heard that owning a U.S. LLC as a nonresident alien is very different from owning one as a resident. What changes and what stays the same?
I'm from Japan — how does my U.S. LLC get taxed?
I am a Japanese citizen living in Tokyo. I formed a Delaware LLC for my e-commerce business selling digital products to U.S. customers. All operations are from Japan. What are my tax obligations to the IRS and the National Tax Agency (NTA)? Japan's tax system is very complex and I want to make sure I'm compliant in both countries.
What are the transfer pricing penalties for foreign-owned LLCs?
My U.S. LLC receives management services from my company overseas and pays fees for those services. The IRS is questioning whether the prices are at arm's length. What transfer pricing penalties could apply, and what is the difference between the 20% and 40% penalty rates?
What are the best U.S. banks for a foreign-owned LLC in 2026?
I just formed my single-member LLC in Wyoming and now I need a U.S. bank account. I live in the UK and won't be visiting the U.S. anytime soon. I've heard that most big banks like Chase and Bank of America won't open accounts for non-resident LLC owners remotely. Which banks actually work for foreign-owned LLCs? I've seen Mercury, Relay, and Wise Business mentioned a lot. Are there meaningful differences between them? I mainly need to receive payments from U.S. clients via ACH and occasionally send international wires back home. Any recommendations from people who've actually gone through the process?
How does corporate tax work in France for a new company or French subsidiary?
I need the practical France answer, not a one-line rate quote. Please explain the 25% headline rate, when the 15% reduced rate can still matter, and what a founder or foreign-owned group should check before assuming only one tax question is in play.
I'm from Canada — how does my U.S. LLC get taxed?
I'm a Canadian citizen and resident in Toronto. I formed a Delaware LLC for my software development freelancing business with U.S. clients. I do all work from Canada. What are my tax obligations in both the U.S. and Canada? I've heard that the CRA treats U.S. LLCs as corporations, which could be a huge problem. Is this true?
Can I use an LLC to hold U.S. real estate and avoid NRA estate tax?
I keep reading online that foreign investors should use an LLC to hold U.S. rental properties to avoid estate tax. The idea seems to be that the LLC creates a layer between you and the property. But my accountant says it's not that simple. Can someone explain whether an LLC actually helps with estate tax for a non-resident alien? I'm from Australia and I'm looking at buying a condo in Miami worth about $800,000.
What are the key differences between Subpart F income and GILTI?
I'm trying to understand the difference between Subpart F and GILTI. They both seem to tax CFC income currently to U.S. shareholders. If GILTI was supposed to be a catch-all for everything not already covered by Subpart F, why do we need both? What are the practical differences in terms of what income is covered, tax rates, deductions, and foreign tax credits? This is driving me crazy.
What are the FBAR penalties for non-willful vs. willful violations?
I have a foreign bank account that I use for my LLC business but I never filed an FBAR (FinCEN Form 114). What is the difference between non-willful and willful FBAR penalties? My account balance was over $100,000 at one point during the year. How much could I owe?
Does First Time Abatement apply to Form 5472 or other international penalties?
I heard the IRS has a First Time Abatement policy that removes penalties for first-time offenders. Does this apply to international information return penalties like Form 5472 or Form 5471? I have a clean compliance history and this is my first penalty ever.
What is GILTI and how do I calculate it on Form 8992?
I own 100% of a controlled foreign corporation (CFC) and my CPA says I need to file Form 8992 for GILTI. I roughly understand that GILTI taxes certain CFC income currently, but I don't understand the calculation. My CFC earned about $300,000 in income and has about $400,000 in depreciable tangible assets. How does the GILTI computation work and what will my actual tax be?
I'm from Germany — how does my U.S. LLC get taxed?
I am a German citizen living in Berlin. I formed a Wyoming LLC for my digital marketing agency serving U.S. clients. I perform all work from Germany. What are my U.S. and German tax obligations? I have heard Germany does not recognize the U.S. disregarded entity concept and that this can create significant tax issues.
Can I use reasonable cause to get Form 5472 penalties removed?
I received a $25,000 penalty notice for not filing Form 5472 for my foreign-owned LLC. My tax preparer in my home country never told me about this form. Can I argue reasonable cause to get the penalty abated? What does the IRS consider a valid reasonable cause defense?
Does cryptocurrency trading through my foreign-owned LLC create effectively connected income (ECI)?
I'm a foreign national living in Singapore and I own a single-member LLC in Delaware. The LLC's main activity is actively trading cryptocurrencies — buying and selling on U.S. exchanges like Coinbase and Kraken, sometimes dozens of trades per day. I've read that trading in stocks and securities for your own account generally does NOT create ECI for foreign persons under the IRC Section 864(b)(2) safe harbor. But does this safe harbor apply to crypto? Crypto isn't technically a "security" or "commodity" under traditional definitions. If crypto trading does create ECI, I'd owe U.S. income tax on all my trading profits. That would be a huge deal. Can anyone clarify the current IRS position?
I run a Shopify store through my foreign-owned LLC — what tax compliance do I need?
I'm from Australia and I have a Delaware LLC that runs a Shopify store selling custom phone cases to U.S. customers. I handle all orders from my home in Sydney — I use a U.S. 3PL (third-party logistics provider) to store and ship products. Shopify collects some sales tax automatically but I'm not sure if that covers me. I don't have any employees in the U.S., just the 3PL warehouse. My revenue last year was about $95,000. What are all the tax things I need to worry about? Federal taxes, state taxes, sales tax, information returns? I feel like I'm missing something important.
How do I file Form 941 for my foreign-owned LLC — what gets reported each quarter?
My foreign-owned LLC started paying employees in February. I know I need to file Form 941 quarterly but I'm not sure what exactly goes on it. Is it just wages and taxes withheld? Do I report the employer's share of FICA too? When are the deadlines for each quarter? I've heard the IRS is strict about late filings for employment tax returns. Can I e-file Form 941 or does it have to be mailed?
What is the Substantial Presence Test under IRC 7701(b) and could I accidentally become a U.S. tax resident?
I'm a Canadian citizen who owns a Delaware LLC for my e-commerce business. I travel to the U.S. about 100 days per year for trade shows and meetings. My accountant warned me about something called the 'Substantial Presence Test' under IRC 7701(b) and said if I spend too many days in the U.S. I could become a tax resident and owe taxes on my worldwide income. How does this test work exactly? Is there a safe number of days I can be in the U.S.? And what happens if I accidentally cross the threshold?
What is the $25,000 penalty for failing to file Form 5472?
I own a single-member LLC as a foreign person and just learned about Form 5472. I never filed it since forming my LLC two years ago. What exactly is the penalty for not filing, and can it really be $25,000 per year? Does the IRS actually enforce this against small foreign-owned LLCs?
Are there any exceptions where FIRPTA withholding doesn't apply? I keep hearing about loopholes.
I'm a German national selling a small investment condo in Texas through my LLC. Sale price is about $250K. I've been told I'll lose 15% to FIRPTA withholding at closing, but a friend said there are exceptions. He mentioned something about a $300K threshold and publicly traded companies. Are there legitimate ways to avoid or reduce the withholding? I don't want to do anything shady, just want to know if there are legal exceptions I might qualify for. The property was never my residence — strictly investment.
What are the five transfer pricing methods and which one should my LLC use?
I've been reading about transfer pricing methods for my foreign-owned LLC and I'm overwhelmed. There's CUP, resale price, cost plus, CPM, profit split — how do I know which one applies to my situation? My LLC provides digital marketing services to clients in the U.S., and my overseas company provides back-office support to the LLC. I also license my brand name to the LLC. Do I need to use a different method for each type of transaction?
What is a year-end tax planning checklist for foreign LLC owners?
The end of the tax year is approaching and I want to make sure I have covered all important tax planning items for my US LLC. As a foreign owner, I know there are unique considerations beyond what domestic owners face. Can you provide a comprehensive checklist of year-end actions I should take to minimize my tax liability and ensure compliance?
What is Subpart F income and how does it apply to foreign-owned business structures?
I've been reading about Subpart F income in the context of CFC rules and I'm confused about how it fits in with GILTI. I'm a U.S. citizen running a business through a foreign corporation. Some of the corporation's income seems to fall into Subpart F categories. Can someone explain what Subpart F actually covers, why it was created, and how it differs from GILTI? I want to understand the full picture of how my foreign corporation's income gets taxed.
I own shares in a foreign mutual fund. Do I need to worry about PFIC rules and Form 8621?
I'm a U.S. resident and before I moved here, I invested about $50,000 in a mutual fund domiciled in Luxembourg through my European brokerage. I've held it for 5 years now and it's grown to about $75,000. I just learned that foreign mutual funds might be classified as PFICs and subject to punitive taxation. What exactly is a PFIC, does my fund qualify, and what do I need to file?
How do I open a U.S. bank account remotely as a foreign LLC owner?
I'm based in Singapore and just got my Wyoming LLC approved along with my EIN. Now I need to open a U.S. business bank account but I can't travel to the States. Every guide I find seems to assume I can walk into a branch. What's the actual step-by-step process for opening a bank account remotely? What documents do I need to have ready? And how long does it typically take from application to having a working account with routing and account numbers? I plan to use this account to receive payments from a SaaS product and eventually pay contractors.
I'm from the UK — how does my U.S. LLC get taxed?
I'm a UK citizen and tax resident living in London. I set up a Wyoming LLC for my online consulting business. I work entirely from the UK and bill U.S. clients through the LLC. What are my U.S. and UK tax obligations? I've heard that HMRC treats U.S. LLCs differently than the IRS does, which sounds like it could cause problems.
What is the 1099-K reporting threshold and does it apply to my foreign-owned LLC?
I keep seeing conflicting information about the 1099-K threshold. Is it $600? $5,000? $20,000? It seems like it changes every year. My foreign-owned LLC receives payments through Stripe and PayPal for an online store. Also, I submitted a W-8BEN-E to both Stripe and PayPal. Does that mean I won't get a 1099-K? Or do I get one regardless because the LLC is a U.S. entity? I want to understand what the IRS actually knows about my income so I can make sure my filing matches.
How are capital gains taxed when a foreign owner sells an LLC?
I am a foreign national who owns a US LLC, and I have received an offer to sell my entire interest in the business. I want to understand how capital gains from the sale will be taxed. Is the gain treated as effectively connected income? What withholding requirements apply? Are there any strategies to minimize the tax impact of selling my LLC interest?
What are the Form 5471 filing requirements for CFC owners?
I just learned I need to file Form 5471 for a foreign corporation I have an interest in. This form looks incredibly complex — it has multiple schedules and categories of filers. Can someone explain which category I fall into, what schedules I need, and what information I need to gather? I'm a U.S. citizen with a 40% stake in a foreign corporation that qualifies as a CFC.
How does the Wayfair decision affect foreign-owned LLCs selling online in the U.S.?
I've been selling products in the U.S. for two years through my Wyoming LLC. I'm from Germany. I recently learned about the Supreme Court's Wayfair decision from 2018 that changed sales tax rules. Does this mean I need to collect sales tax in every state where I make sales? I sell about $500,000/year across the U.S. Most of my sales are through my own website, not Amazon.
I'm from the UAE — how does my U.S. LLC get taxed?
I'm a UAE resident living in Dubai. I formed a Wyoming LLC for my online consulting business. The UAE recently introduced corporate tax, but it has a high threshold. What are my U.S. and UAE tax obligations? I've heard that combining a UAE residency with a U.S. LLC can be very tax-efficient.